Luna Simone Hotel Privacy Policy & Cookie Policy

Desira Hotels Ltd, Trading as Luna Simone

25th May 2018

Background:

Desira Hotels Ltd, Trading as Luna Simone understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and any third-party systems we use If you do not accept and agree with this Privacy Policy, you should stop using Our Site immediately

1.Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”

means an account required to access and/or use certain areas and features of Our Site and our associated third-party websites and systems;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and our associated third-party websites and systems and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]

“Our Site”

means this website, https://www.lunasimonehotel.com/;

“United Kingdom and EU Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]

“We/Us/Our”

means Desira Hotels Ltd, a limited company registered in England under 02977131, whose registered address is 47/49 Belgrave Road, London, SW1V 2BB and whose main trading address is 47/49 Belgrave Road, London, SW1V 2BB.  

2. Information About Us

2.1 Our Site, https://www.lunasimonehotel.com/, is owned and operated by Desira Hotels Ltd, [ a limited company registered in England under 02977131, whose registered address is 47/49 Belgrave Road, London, SW1V 2BB and whose main trading address is  47/49 Belgrave Road, London, SW1V 2BB. Our VAT number is 394791596.

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What Data Do We Collect?

Some data will be collected automatically by Our Site (for further details, please see section 12 on Our use of Cookies and Our Cookie Policy, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Desira Hotels Ltd, We may collect some or all of the following data:

When staying with Desira Hotels ltd
4.1 name;
4.2 date of birth, passport number;
4.3 gender;
4.4 business/company name;
4.5 job title;
4.6 profession;
4.7 demographic information such as postcode, preferences and interests;
4.8 contact information such as email addresses and telephone numbers;

When using Our Site
4.8 contact information such as email addresses and telephone numbers;
4.9 financial information such as credit / debit card numbers;
4.10 IP address (automatically collected);
4.11 web browser type and version (automatically collected);
4.12 operating system (automatically collected);
4.13 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);

5. How Do We Use Your Data?

5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.

5.2 We use your data to provide the best possible services to you. This includes:

5.2.1 Providing and managing your Account;

5.2.2 Providing and managing your access to Our Site;

5.2.3 Personalising and tailoring your experience on Our Site;

5.2.4 Supplying Our services to you;

5.2.5 Personalising and tailoring Our services for you;

5.2.6 Responding to communications from you;

5.2.7  Supplying you with email Insert Type of Email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by Insert Description of Unsubscription Method;

5.2.8  Market research;

5.2.9  Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the [products and] services We can provide you without your consent for Us to be able to use such data.

5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.5 Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.

5.6 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.  We will only process your personal data if at least one of the following basis applies:

a) you have given consent to the processing of your personal data for one or more specific purposes;

b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

c) processing is necessary for compliance with a legal obligation to which we are  subject;

d) processing is necessary to protect the vital interests of you or of another natural person;

e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6. How and Where Do We Store Your Data?

6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.  In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:

6.2 Your data will only be stored in the United Kingdom.

6.3  Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.

6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

7. Do We Share Your Data?

7.1 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with.

7.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

7.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What Happens If Our Business Changes Hands?

8.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

8.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

9. How Can You Control Your Data?

9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data, and we aim to only hold your data throughout your stay, so that we can provide a high level of service to you, after which it is deleted. We are, however, legally obliged to keep some aspects of your data for as long as necessary in accordance with British Law.

9.2 You may also wish to sign up to one or more of the preference services operating in the United Kingdom: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

10.1  You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

10.2 You may restrict your internet browser’s use of Cookies. For more information, see section 12 and Our Cookie Policy Insert Link.

10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems.  However, you acknowledge this may limit Our ability to provide the best possible services to you.

11. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at stay@lunasimonehotel.com, or using the contact details below in section 14.

12. What Cookies Do We Use and What For?

12.1 Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

12.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.

12.3 All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.

12.4 Before any Cookies are placed on your computer or device, subject to section 12.5 AND section 12.8, you will be shown a message bar etc. requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.

12.5  Certain features of Our Site depend on Cookies to function. United Kingdom and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

12.6 the following third party Cookies may be placed on your computer or device:

12.7 Our Site uses analytics services provided by Google Analytics on behalf of both Luna Simone. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the  services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

12.8  The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Some of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.

12.9 The analytics service(s) used by Our Site use(s) the following Cookies: